To recognize a cause of action for negligent spoliation would lead to derivative litigation by parties to the underlying action against other parties and third parties, contrary to the policy against creating derivative tort remedies for litigation-related misconduct and favoring the resolution of a dispute in a single lawsuit. (See Cedars-Sinai Medical Center v. Superior Court (1998), 18 Cal. 4th at pp. 8-11; Temple Community Hospital v. Superior Court (1999), 20 Cal. 4th at pp. 471-472.) Litigants seeking to avoid the effect of a prior judgment could commence another action, threatening the finality of the original adjudication and potentially leading to endless litigation. (See Cedars-Sinai, supra, 18 Cal. 4th at pp. 8-11; Temple Community, supra, 20 Cal. 4th at pp. 472-473.) The spoliation claim would require a retrial within a trial in which all the evidence presented in the underlying action would be presented again for the trier of fact to determine what effect the spoliated evidence might have had in light of the other evidence. (See Cedars-Sinai, supra, 18 Cal. 4th at p. 16; Temple Community, supra, 20 Cal. 4th at p. 475.) The trier of fact would have to speculate as to the nature of the missing evidence and the effect that it might have had in the underlying action, rendering the fact of harm and causation "irreducibly uncertain" and creating the potential for arbitrary and inconsistent results. (See Cedars-Sinai, supra, 18 Cal. 4th at pp. 13-14, 16-17; Temple Community, supra, 20 Cal. 4th at pp. 474-475.) If the spoliation claim were tried in the same lawsuit as the underlying cause of action, the potential for jury confusion and inconsistent results would be great. (See Cedars-Sinai, supra, 18 Cal. 4th at p. 16; Temple Community, supra, 20 Cal. 4th at p. 472.) The risk of meritless claims for negligent spoliation is particularly troublesome in light of the uncertainty concerning the nature of the missing evidence and its potential effect in the underlying litigation, and the fact that documents and other evidence often are destroyed without fault in the ordinary course of events. (See Cedars-Sinai, supra, 18 Cal. 4th at pp. 15-16; Temple Community, supra, 20 Cal. 4th at p. 470.) Potential liability for negligent spoliation could cause individuals and entities to take extraordinary measures to retain documents and other things, at substantial costs. (See Cedars-Sinai, supra, 18 Cal. 4th at p. 15; Temple Community, supra, 20 Cal. 4th at p. 476.) Although the nontort remedies available to a victim of negligent spoliation appear to be very limited, even more so than the remedies available to a victim of third party intentional spoliation, that circumstance alone does not override the other policy considerations that weigh against providing a tort remedy. (See Temple Community, supra, 20 Cal. 4th at p. 477.)